Impact on TMT industry from Union Budget 2020aakash malhotra
The budget inter-alia aims to focus on three important aspects: ease of living, ease of doing business, and ease of transactions. Several policy measures are proposed for harnessing the potential of disruptive technologies such as Artificial intelligence, Internet of things (IOT), 3D printing, drones, etc. See More https://www2.deloitte.com/in/en/pages/pages/tax/articles/in-tmt-budget-expectations-noexp.html
Impact on TMT industry from Union Budget 2020aakash malhotra
The budget inter-alia aims to focus on three important aspects: ease of living, ease of doing business, and ease of transactions. Several policy measures are proposed for harnessing the potential of disruptive technologies such as Artificial intelligence, Internet of things (IOT), 3D printing, drones, etc. See More https://www2.deloitte.com/in/en/pages/pages/tax/articles/in-tmt-budget-expectations-noexp.html
Finance Act 2020 not only infused a new TDS provision for E-commerce business in India, it also brought in new Equalization Levy at 2% on E-commerce Operators (non-resident) thereby widening the tax base for the growing digital economy.
RBSA-Budget-Finance Bill 2023-Key Proposals.pdfRBSA Advisors
Keeping a people-centric approach, various amendments in individual tax provisions and amendments providing benefits under the new tax-rate regime is a welcome move.
Corporate tax will be levied for all businesses(extraction of natural resources is excluded) and commercial activities across all the emirates in the UAE.
Finance Act 2020 not only infused a new TDS provision for E-commerce business in India, it also brought in new Equalization Levy at 2% on E-commerce Operators (non-resident) thereby widening the tax base for the growing digital economy.
RBSA-Budget-Finance Bill 2023-Key Proposals.pdfRBSA Advisors
Keeping a people-centric approach, various amendments in individual tax provisions and amendments providing benefits under the new tax-rate regime is a welcome move.
Corporate tax will be levied for all businesses(extraction of natural resources is excluded) and commercial activities across all the emirates in the UAE.
As a supplement to our China Tax Alert, China Tax Bulletin aims to provide on a bi-monthly basis a high level overview on the latest tax rules released by various authorities, especially those by China SAT and local tax authorities and the implications for businesses.
6 Tax Considerations for the Real Estate Sector under Recent COVID-19 Legisla...CBIZ, Inc.
Tax planning may not be a priority as real estate groups respond and recover to COVID-19 pandemic disruption, but recent legislation provides some significant opportunities that are worth a closer look. This article discusses the careful consideration and planning required to determine an appropriate strategy to optimize income tax obligations under these provisions.
Grant Thornton China tax bulletin - January 2015Alex Baulf
China Tax Bulletin aims to provide a prompt and high level overview on the latest tax rules released by various authorities, especially those by China SAT and local tax authorities. Implications for your business are also presented for the tax rules
Join us for an exclusive and informative webinar as we delve into the exciting new updates and features of Sage Intacct's highly anticipated Release 3 for 2023! Discover how these enhancements will streamline your financial management processes, boost productivity, and empower your team with powerful tools for smarter decision-making.
We will walk you through the latest innovations, providing practical insights and real-world use cases to maximize the benefits of Intacct. After the webinar, you will be able to:
Recognize new release features for your business solution
Demonstrate the new user experience and navigation to ease
Manage the latest release of the solution to maximize its potential
Congressional Update on Potential Tax Legislation For You and Your Business.pptxWithum
Many taxpayers have been closely monitoring Congress to see if tax extenders could provide much needed federal income tax relief regarding the 2021 and 2022 Tax Cuts and Jobs Act sunset provisions, including R&E capitalization and the tightening of the interest expense limitation rules. On Friday June 9th, the House of Representatives introduced three bills in the House Ways and Means Committee that could alleviate burdens placed on privately owned businesses.
Learning Objectives
• Analyze the Tax Cuts and Jobs Act sunset provisions for the 2022 and 2023 taxable years.
• Assess the new tax law proposed in the Build It In America, Small Business Jobs, and Tax Cuts and Working Families Acts.
• Evaluate the US budgetary impact of the proposals.
Power Platform Governance Center of ExcellenceWithum
Unlock the full potential of Microsoft Power Platform and effectively govern your low-code applications and citizen developers. Learn how to define, monitor, track, govern, and perfect your Power Platform adoption and strategy, allowing you to focus on what you love most.
Safeguarding Your Law Firm Against Cyber ThreatsWithum
Law firms serve as stewards to valuable, sensitive financial and client information and must remain as trusted business partners.
With the scope and severity of cybercrimes rising, don’t wait to optimize your firm’s approach to cybersecurity. Join Edward Keck Jr., Partner and Practice Leader of Withum’s Cyber and Information Security practice, and Bill Sansone, Partner and Practice Leader of Withum’s Law Firm Advisory team, to learn:
• How to manage the cybersecurity risks affecting law firms, including data breaches
• The value of going beyond what’s required to operate effectively in today’s digital landscape
• How to apply data security best practices and maintain good cyber hygiene at your firm
Navigating Through Uncertain Times: An Economic Update for Manufacturers with...Withum
All companies in the supply chain are impacted by the current economic conditions and the uncertainties in front of us. To successfully navigate these times, businesses have been forced to consider new strategies, develop new alliances and pivot quickly to react to market demands.
Put Your NetSuite Data to Work – Discover Better NetSuite ReportingWithum
Reporting tools can help businesses make valuable data-driven decisions that can ensure your organization’s success. Whether you’re already using Oracle NetSuite or perhaps you’ve thought about it - learn how a built-for NetSuite reporting solution helps quickly build reports that improve business performance.
Withum’s NetSuite Lead, Chris Higgins, and special guest Josh LaSov, Founder of ZoneReporting (formerly Satori) share:
• A limitless reporting solution built for NetSuite by NetSuite experts in the #1 ranked BI tool – Power BI
• How 50+ pre-built reports provide business insights on Day 1
• Why integrating your other data sources with your NetSuite data is critical for end-to-end reporting
IRS Audits of The Employee Retention Credit 2.16.23.pdfWithum
Over the past several months, we have seen a significant uptick in IRS audits of the Employee Retention Credit (ERC). This session will address the details of the ERC with a focus on strategies to successfully resolve your IRS audit without adjustment. We will also share our experiences on what we have seen during these audits.
International Tax and TP in the Metaverse 2.9.23.pptxWithum
Join a panel of international tax and transfer pricing professionals with expertise in taxation of digital assets, blockchain technology, and the metaverse.
CMMC for Contractors and Manufacturers – What to Know for 2023Withum
Manufacturers, contractors, and suppliers who are members of (and/or affiliated with) the U.S. Defense Industrial Base (DIB) must prepare now to ensure assessment readiness. Fears of a near-term enormous bureaucratic traffic jam are arising as tens of thousands of SMBs scramble to become CMMC compliant to avoid administrative exclusion from the DOD bidding process.
Sales Use Tax Opportunities and Traps Affecting Your BusinessWithum
Join us to discuss new developments regarding how the Wayfair decision has affected businesses and the related sales tax compliance requirements. The team will also discuss opportunities such as common exemptions to identify potential refunds, potential audit triggers, and other sales tax trends including collections, remittance, and software solutions.
Webinar: Year-End Planning Steps for Success in 2022 11.29.2022.pdfWithum
Join Withum's tax experts for a timely overview on how you can minimize your tax bill this year.
Learn what steps you can take now to set your company up for success in 2022.
Lessons from the First 100 Days of Recreational Cannabis in New JerseyWithum
Withum’s Cannabis Sector Team and NJ Cannabis Regulatory Commissioner, Krista Nash, discussed new tax policies, and shared our unique insights and predictions for this robust industry.
6 Ways to Accelerate Your Multichannel GrowthWithum
Is your inventory tracking system aligned with your e-commerce platform? Are you having trouble reconciling your payments?
Learn how to remove inventory and payment processing roadblocks and discover a seamless path to growth.
Is There A Union In Your Future? Understanding Cannabis Labor Peace AgreementsWithum
Labor peace requirements instilled by state legislators will materially change U.S. cannabis businesses. California, Rhode Island, New York, New Jersey, Pennsylvania and Virginia are already requiring players in the cannabis market to enter a Labor Peace Agreement (LPA) as a condition to licensing. At least five other states and many municipalities do not require an LPA, but instead offer preferential treatment in a competitive licensing process to those who have signed one.
Withum welcomed Richard S. Rosenberg, Partner at Ballard Rosenberg Golper & Savitt, LLP to share his expertise on cannabis labor peace agreements. Richard is a management-side labor attorney who has extensive experience representing cannabis companies in connection with their LPA negotiations. Richard will explain what signing an LPA really means for your business now and into the future.
Using Cutting Edge Engagement Tools to Improve Talent RetentionWithum
Tech companies and other progressive businesses had been working remotely long before the pandemic and learned over the years how to use innovative tools to improve employee performance management and engagement in remote and hybrid environments. In this session, 15Five will share best practices and case studies lessons learned in companies leading the way in employee engagement and corporate culture and how you can apply them in your law firm.
This CPE webinar will explore Public Law 86-272, which was enacted to protect taxpayers from state income taxes when their sole activity in the state is limited to the solicitation and sale of tangible personal property. State tax authorities have been contesting this federal law ever since passage. Due to the rise of the digital economy, taxpayer protection under P.L. 86-272 has been steadily eroding.
On the final stop for our virtual Global Summit Series, Withum’s International Team proudly presents Dr. Kevin Lyons, Supply Chain Management Department and Director, Public Private Community Partnerships of Rutgers Business School, on a deep dive into how climate change will affect culture and global supply chains.
He will be providing insight into how the global community can start to think about what we can do together to minimize the impacts of climate change on our culture and the supply chains that also connect us. From this presentation international and domestic companies can gain a better understanding on how these impacts may surface in their day-to-day operations as well as long term company profits.
RMD24 | Debunking the non-endemic revenue myth Marvin Vacquier Droop | First ...BBPMedia1
Marvin neemt je in deze presentatie mee in de voordelen van non-endemic advertising op retail media netwerken. Hij brengt ook de uitdagingen in beeld die de markt op dit moment heeft op het gebied van retail media voor niet-leveranciers.
Retail media wordt gezien als het nieuwe advertising-medium en ook mediabureaus richten massaal retail media-afdelingen op. Merken die niet in de betreffende winkel liggen staan ook nog niet in de rij om op de retail media netwerken te adverteren. Marvin belicht de uitdagingen die er zijn om echt aansluiting te vinden op die markt van non-endemic advertising.
Putting the SPARK into Virtual Training.pptxCynthia Clay
This 60-minute webinar, sponsored by Adobe, was delivered for the Training Mag Network. It explored the five elements of SPARK: Storytelling, Purpose, Action, Relationships, and Kudos. Knowing how to tell a well-structured story is key to building long-term memory. Stating a clear purpose that doesn't take away from the discovery learning process is critical. Ensuring that people move from theory to practical application is imperative. Creating strong social learning is the key to commitment and engagement. Validating and affirming participants' comments is the way to create a positive learning environment.
Personal Brand Statement:
As an Army veteran dedicated to lifelong learning, I bring a disciplined, strategic mindset to my pursuits. I am constantly expanding my knowledge to innovate and lead effectively. My journey is driven by a commitment to excellence, and to make a meaningful impact in the world.
[Note: This is a partial preview. To download this presentation, visit:
https://www.oeconsulting.com.sg/training-presentations]
Sustainability has become an increasingly critical topic as the world recognizes the need to protect our planet and its resources for future generations. Sustainability means meeting our current needs without compromising the ability of future generations to meet theirs. It involves long-term planning and consideration of the consequences of our actions. The goal is to create strategies that ensure the long-term viability of People, Planet, and Profit.
Leading companies such as Nike, Toyota, and Siemens are prioritizing sustainable innovation in their business models, setting an example for others to follow. In this Sustainability training presentation, you will learn key concepts, principles, and practices of sustainability applicable across industries. This training aims to create awareness and educate employees, senior executives, consultants, and other key stakeholders, including investors, policymakers, and supply chain partners, on the importance and implementation of sustainability.
LEARNING OBJECTIVES
1. Develop a comprehensive understanding of the fundamental principles and concepts that form the foundation of sustainability within corporate environments.
2. Explore the sustainability implementation model, focusing on effective measures and reporting strategies to track and communicate sustainability efforts.
3. Identify and define best practices and critical success factors essential for achieving sustainability goals within organizations.
CONTENTS
1. Introduction and Key Concepts of Sustainability
2. Principles and Practices of Sustainability
3. Measures and Reporting in Sustainability
4. Sustainability Implementation & Best Practices
To download the complete presentation, visit: https://www.oeconsulting.com.sg/training-presentations
Premium MEAN Stack Development Solutions for Modern BusinessesSynapseIndia
Stay ahead of the curve with our premium MEAN Stack Development Solutions. Our expert developers utilize MongoDB, Express.js, AngularJS, and Node.js to create modern and responsive web applications. Trust us for cutting-edge solutions that drive your business growth and success.
Know more: https://www.synapseindia.com/technology/mean-stack-development-company.html
Skye Residences | Extended Stay Residences Near Toronto Airportmarketingjdass
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Falcon stands out as a top-tier P2P Invoice Discounting platform in India, bridging esteemed blue-chip companies and eager investors. Our goal is to transform the investment landscape in India by establishing a comprehensive destination for borrowers and investors with diverse profiles and needs, all while minimizing risk. What sets Falcon apart is the elimination of intermediaries such as commercial banks and depository institutions, allowing investors to enjoy higher yields.
What is the TDS Return Filing Due Date for FY 2024-25.pdfseoforlegalpillers
It is crucial for the taxpayers to understand about the TDS Return Filing Due Date, so that they can fulfill your TDS obligations efficiently. Taxpayers can avoid penalties by sticking to the deadlines and by accurate filing of TDS. Timely filing of TDS will make sure about the availability of tax credits. You can also seek the professional guidance of experts like Legal Pillers for timely filing of the TDS Return.
Implicitly or explicitly all competing businesses employ a strategy to select a mix
of marketing resources. Formulating such competitive strategies fundamentally
involves recognizing relationships between elements of the marketing mix (e.g.,
price and product quality), as well as assessing competitive and market conditions
(i.e., industry structure in the language of economics).
Attending a job Interview for B1 and B2 Englsih learnersErika906060
It is a sample of an interview for a business english class for pre-intermediate and intermediate english students with emphasis on the speking ability.
Kseniya Leshchenko: Shared development support service model as the way to ma...Lviv Startup Club
Kseniya Leshchenko: Shared development support service model as the way to make small projects with small budgets profitable for the company (UA)
Kyiv PMDay 2024 Summer
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Memorandum Of Association Constitution of Company.pptseri bangash
www.seribangash.com
A Memorandum of Association (MOA) is a legal document that outlines the fundamental principles and objectives upon which a company operates. It serves as the company's charter or constitution and defines the scope of its activities. Here's a detailed note on the MOA:
Contents of Memorandum of Association:
Name Clause: This clause states the name of the company, which should end with words like "Limited" or "Ltd." for a public limited company and "Private Limited" or "Pvt. Ltd." for a private limited company.
https://seribangash.com/article-of-association-is-legal-doc-of-company/
Registered Office Clause: It specifies the location where the company's registered office is situated. This office is where all official communications and notices are sent.
Objective Clause: This clause delineates the main objectives for which the company is formed. It's important to define these objectives clearly, as the company cannot undertake activities beyond those mentioned in this clause.
www.seribangash.com
Liability Clause: It outlines the extent of liability of the company's members. In the case of companies limited by shares, the liability of members is limited to the amount unpaid on their shares. For companies limited by guarantee, members' liability is limited to the amount they undertake to contribute if the company is wound up.
https://seribangash.com/promotors-is-person-conceived-formation-company/
Capital Clause: This clause specifies the authorized capital of the company, i.e., the maximum amount of share capital the company is authorized to issue. It also mentions the division of this capital into shares and their respective nominal value.
Association Clause: It simply states that the subscribers wish to form a company and agree to become members of it, in accordance with the terms of the MOA.
Importance of Memorandum of Association:
Legal Requirement: The MOA is a legal requirement for the formation of a company. It must be filed with the Registrar of Companies during the incorporation process.
Constitutional Document: It serves as the company's constitutional document, defining its scope, powers, and limitations.
Protection of Members: It protects the interests of the company's members by clearly defining the objectives and limiting their liability.
External Communication: It provides clarity to external parties, such as investors, creditors, and regulatory authorities, regarding the company's objectives and powers.
https://seribangash.com/difference-public-and-private-company-law/
Binding Authority: The company and its members are bound by the provisions of the MOA. Any action taken beyond its scope may be considered ultra vires (beyond the powers) of the company and therefore void.
Amendment of MOA:
While the MOA lays down the company's fundamental principles, it is not entirely immutable. It can be amended, but only under specific circumstances and in compliance with legal procedures. Amendments typically require shareholder
LA HUG - Video Testimonials with Chynna Morgan - June 2024Lital Barkan
Have you ever heard that user-generated content or video testimonials can take your brand to the next level? We will explore how you can effectively use video testimonials to leverage and boost your sales, content strategy, and increase your CRM data.🤯
We will dig deeper into:
1. How to capture video testimonials that convert from your audience 🎥
2. How to leverage your testimonials to boost your sales 💲
3. How you can capture more CRM data to understand your audience better through video testimonials. 📊
Affordable Stationery Printing Services in Jaipur | Navpack n PrintNavpack & Print
Looking for professional printing services in Jaipur? Navpack n Print offers high-quality and affordable stationery printing for all your business needs. Stand out with custom stationery designs and fast turnaround times. Contact us today for a quote!
Business Valuation Principles for EntrepreneursBen Wann
This insightful presentation is designed to equip entrepreneurs with the essential knowledge and tools needed to accurately value their businesses. Understanding business valuation is crucial for making informed decisions, whether you're seeking investment, planning to sell, or simply want to gauge your company's worth.
2. withum.com
Topics
• Extended datesforfilingForm s990,990-EZ,990-PF and 990-and paym entofam ountsdue
• A non-item izerscontribution deduction for2020 and increased 2020 item izerand corporatecontribution
deduction lim itations
• A singleIRC Section 4940 tax rateforprivatefoundation netinvestm entincom e
• TherescindingoftheIRC Section 512(a)(7)application oftheunrelated businessincom etax to em ployer
provided parking
• Proposed regulationsforIRC Section 512(a)(6),the"siloing"ruleforunrelated businessincom egenerating
activitiesand netoperatinglosses
• Proposed regulationsfordonoradvised funds(DA Fs)
• Eventticketsbenefitingdonors
• Satisfaction ofdonorpledges
• Publicsupportim plicationsfordonoradvised fund granteecharities
• N ew proposed regulationson IRC Section 4960,theexcisetax on excess tax on com pensation over
$1,000,000
• O ther
3. withum.com
Extended Filingand Paym entDates
• N otice2020-18
• Issued M arch 18,2020 extended duedateforfilingindividualtax returns
and payingtax liability ofup to$1,000,000 toJuly 15,2020
Theoriginalduedateofthereturn tobefiled had tobeA pril15
Thereturn had to beforthe2019tax year
Theform tobefiled had beatax return
• Form 990 isconsidered tobean inform ation return ratherthan atax return
undertheInternalRevenueCodeand Treasury Regulations
So,only trustsororganizationsorcorporationsw ith shorttax yearsendingin N ovem ber2019
could delay their990-T filingorpaym entand pension trustsfilingForm theircalendaryear
Form 990-T on A pril15th qualified
• N oticehad tobeexplained in Q uestionsand A nsw ersissued on M arch 24th
4. withum.com
Extended Filingand Paym entDates
• N otice2020-23
• Issued A pril9,2020,thenoticeam plified and extended thereach ofN otices2020-
18 and N otice2020-20
• Providesadditionalrelieftoaffected taxpayersw ith afederaltax paym ent
obligation orfederaltax return orotherform filingobligation,w hich isduetobe
perform ed (originally orpursuanttoavalid extension thatends)on orafterA pril1,
2020,and beforeJuly 15,2020,an autom aticpostponem enttofileand/orpay to
July 15,2020
• A lsogranted relieftoavariety oftim e-sensitiveactions,includingthoselisted in
Rev.Proc.2018-58.Section 10 ofRev.Proc.2018-58 coverscertain tax-exem pt
entitiesassum ingthey qualify asan affected taxpayer.A ffected taxpayersare
defined in theN oticeasany person ororganization perform inga“tim e-sensitive
action”betw een A pril1,2020,and beforeJuly 15,2020.Tim e-sensitiveactions
relevanttononprofitsand foundationsinclude:
• ThefilingofForm 990 seriesannualreturns
• ThefilingofForm 1023,A pplication forRecognition ofExem ption under501(c)(3)
• Tax-exem pthospitalorganizationsconductingacom m unity health needsassessm ent
5. withum.com
Extended Filingand Paym entDates
• N otice2020-23
• Form s990,990T and 990-PF Extension Rules
• Form 990sw ith aprevioussix-m onth extension tofilem ustfileon orbeforeJuly 15,2020.Ifthe
originalduedateofForm 990 isM ay 15,2020,theorganization m ay either:
Filean extension oftim ethrough N ovem ber15,2020,on orbeforeM ay 15,2020
Filean extension oftim etofileon orbeforeJuly 15,2020,extendingthefinalduedatetoN ovem ber15,
2020
Thenoticeprovided an expansivelistoffederalreturnsand paym entsapplicabletotax-exem pt
organizationsw ith an originalduedateofM ay 15,2020.Thosequalifyingunderthispostponem ent
include:
Form 990,Return ofO rganization Exem ptFrom Incom eTax
Form 990-T,Exem ptO rganization BusinessIncom eTax Return
Form 990-PF,Return ofPrivateFoundation
Form 4720,Return ofCertain ExciseTaxesunderChapters41and 42oftheInternalRevenueCode
6. withum.com
Extended Filingand Paym entDates
• N otice2020-23
• Reliefisautom atic;affected taxpayersdonothavetocalltheIRS,fileany
extension form sorsend lettersorotherdocum entstoreceivethisrelief
• A ffected taxpayersw honeed additionaltim etofilem ay choosetofilethe
appropriateextension form by July 15,2020,toobtain theextension
• A llfilingsm ay notgobeyond theoriginalstatutory orregulatory extension date
7. withum.com
Increased A GILim itation and N on-Item izer
D eduction
• CoronavirusA id,Relief,and Econom icSecurity A ct,(CA RESA ct)
• Expandsindividualdonors’A djusted GrossIncom e(A GI)lim itation from
60% to100% for2020 sothatindividualsm ay receivetax benefitsfrom
m akinglargercharitablegifts,how ever,doesnotapply toprivate
foundation,donoradvised fund and supportingorganization gifts
• Includescontributionsfrom pass-through entities
• N on-item izersdeduction foraggregatecash contributionsofup to$300
added for2020 contributionstopubliccharitiesotherthan donoradvised
fundsand orsupportingorganizations
8. withum.com
PollingQ uestion #1
• In ordertobenefitfrom theextended July 15,2020 duedatefora
Form 990 w ith acalendaryearend itw asnecessary tophonethetoll-
freenum beroftheIRSon orbeforeM ay 15,2020?
A . True
B. False
10. withum.com
SingleIRC Section 4940 Tax Rate
• TheFurtherConsolidated A ppropriationsA ct,2020 (FCA A )
• M odification tothecurrenttw o-tierexcisetax structureforprivate
foundationson theirinvestm entincom eunderIRC Section 4940 w illam end
Section 4940(a)by changingthecurrent2% rateto1.39% and by strikingout
Section 4940(e)w hich allow ed forareduced tax rateof1% forprivate
foundationsthatm eetcertain distribution requirem ents
• Fortax periodsbeginningafterD ecem ber20,2019
11. withum.com
PollingQ uestion #2
• Thenew ly enacted tax ratefortheprivatefoundation excisetax on
netinvestm entincom eunderIRC Section 4940 is?
A . 1.2%
B. 1.39%
C. 2.4%
D. N oneoftheabove
12. withum.com
RepealoftheN onprofitTax on Q ualified
Transportation FringeBenefits
• TheFurtherConsolidated A ppropriationsA ct,2020 (FCA A )
• Rescission ofIRC Section 512(a)(7)
• Provision ofparkingand transitpassestoem ployeesw illrem ain tax free,
how ever,thefairm arketvalueoveracertain m onthly am ount($265in 2019
and $270 in 2020)rem ainstaxabletoem ployees
13. withum.com
RepealoftheN onprofitTax on Q ualified
Transportation FringeBenefits
• TheFurtherConsolidated A ppropriationsA ct,2020 (FCA A )
• O n January 21,2020 theIRSissued instructionson how toclaim arefund for
thenow repealed Q ualified Transportation Fringeam ountsthatw ere
subjecttoUnrelated BusinessIncom eTax (UBIT)
• Tim elim itsforfilingrefund claim sfound in IRC Section 6511apply tothese
refunds.Typically,thisisthreeyearsfrom thelaterofthetim etheoriginal
Form 990-T w asfiled ortw oyearsfrom thetim ethetax w aspaid
14. withum.com
RepealoftheN onprofitTax on Q ualified
Transportation FringeBenefits
• IRSInstructionsForO btainingRefunds
• https://w w w .irs.gov/form s-pubs/how -to-claim -a-refund-or-credit-of-
unrelated-business-incom e-tax-ubit-or-adjust-form -990-t-for-qualified-
transportation-fringe-am ounts
16. withum.com
Proposed SiloRegulationsReleased
• O n A pril23,2020,theTreasury D epartm entand InternalRevenueService
(“IRS”)issued Proposed Regulations(REG-106864-18)w hich provided
furtherguidanceon calculatingunrelated businesstaxableincom e(“UBTI”)
forseparatetradesorbusinesses
• Theseproposed Regulationsexpand upon theinterim guidancepreviously issued
w ithin IRSN otice2018-67
• TheTax Cutsand JobsA ctof2017 added InternalRevenueCode(“IRC”)§512(a)(6),
w hich requirestax-exem ptorganizationstocom puteUBTIseparately foreach
unrelated tradeorbusiness(“UTB”)activity (referred toasa“silo”or“siloing”).This
rulegenerally preventstax-exem ptorganizationsfrom usinglossesfrom oneUTB
tooffsetincom efrom anotherUTB
• Proposed Regulationslargely rem ain consistentw ith theguidancein IRSN otice2018-67’how ever,
certain m odificationsw erem adein responsetocom m entsreceived in ordertoreducetheburden
im posed by thenew silorules
17. withum.com
Proposed SiloRegulationsReleased
• N A ICSCodes
• A doption oftw o-digitN A ICScodesin placeofthem orespecificsix-digit
codesw hich w illallow tax-exem ptorganizationstouseonly thefirsttw o
digitsoftheN A ICScodetocategorizeeach UTB,allow ingforbroader
classification ofactivities
• O ncean organization usesthetw o-digitcodetoclassify aUTB,itgenerally
cannotchangethecodeunlesstherew asan unintentionalerrorin the
initialclassification
18. withum.com
Proposed SiloRegulationsReleased
• Investm entA ctivities
• Proposed Regulationsprovidethatatax-exem ptorganization m ay treat
investm entactivitiescollectively asaseparateUTB w hich allow sallincom e,
deductibleexpenses,and lossesfrom thefollow inginvestm entactivitiesto
beaggregated in com putingasingleUBTIam ount:
• Q ualifyingpartnership interests(“Q PIs”);
• Q ualifyingSCorporation interests;and
• D ebt-financed properties
20. withum.com
Proposed SiloRegulationsReleased
• Investm entA ctivities
• A qualifyingScorporation interestm ustm eetthedefinition ofaQ PI,
consideringthepercentageofstock ow ned ratherthan aprofitsinterest.In
addition,theproposed Regulationsalso providethateach SCorporation
interestthatisnota “qualifyingSCorporation”interestisconsidered to be
itsow n separatetradeorbusiness.H ow ever,tax-exem ptorganizations
m ustaggregatetheinterestsofitssupportingorganizationsand §512(b)(13)
controlled organizationsw hen determ ining ow nership.
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Proposed SiloRegulationsReleased
• N etO peratingLosses(N O Ls)
• Theproposed Regulationsprovidethattax-exem ptorganizationsw ith pre-
2018 and post-2017 N O Lsshould firstdeductitspre-2018N O Lsfrom its
aggregateUBTIsoastofully utilizeitspre-2018N O Ls.Post-2017 N O Ls
should bededucted thereafterw ith respecttoeach UTB activity under
§512(a)(6)(A ).
• FA Q sissued on N O Ls6/9
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Proposed SiloRegulationsReleased
• O therProvisions
• Controlled organizations–A ll“specified paym ents”(includingrent,interest,and
royalties)from acontrolled entity w ould betreated asgrossincom efrom aseparate
tradeorbusiness.Ifan organization receivesspecified paym entsfrom m ultiple
controlled entities,thepaym entsfrom each controlled entity aretreated as
separatetradesorbusinesses;
• Controlled foreign corporations(“CFCs”)–A llincom efrom CFC insuranceactivities
under§512(b)(17)istreated collectively asonetradeorbusiness,even ifreceived
from m ultipleCFCs;
• A djusted gross-to-grossm ethod –W hen allocatingindirectexpensestoUBI,this
m ethod had been deem ed unreasonable;and
• Publicsupporttests–Theproposed Regulationsprovideafavorableruleallow ing
organizationstoaggregateallnetincom eand netlossesfrom unrelated business
activitiesforpurposesofpublicsupportcalculations
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PollingQ uestion #3
• W ith respecttoan exem ptorganization’sunrelated tradeorbusiness
activities,N A ICSCodesofhow m any lettersw illbeused for
classification ofUTB activities?
A . 2digits
B. 3digits
C. 6digits
D. N oneoftheabove
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DonorA dvised Funds(DA Fs)
• N otice2017-73,RequestforCom m entson A pplication ofExciseTaxes
W ith RespecttoDonorA dvised Fundsin Certain Situations(“N otice”)
released D ecem ber12/4/17
• Proposed thatnobifurcation w ith respecttoeventparticipation beallow ed
• DA F donororadvisor could nolongerpay nondeductibleportion ofeventparticipation
personally
Section 4967 ExciseTax A pplies
• D istribution from DA F toacharity in satisfaction ofdonororadvisorpledgew illw ould
notresultin m orethan an incidentalbenefit,even,iftreated by charity asbeingin
satisfaction ofthepledge,provided DA F m akesnoreferencetothepledgein m akingthe
distribution
O therw iseSection 4967ExciseTax applies
Taxpayersm ay rely on thisportion oftheguidanceuntiladditionalguidanceisissued
25. withum.com
DonorA dvised Funds(DA Fs)
• A ICPA Com m ents7/24/19
• D istributionsfrom DA F:
• Should betreated asagrantfrom theDA F donorratherthan theDA F sponsor
• A llanonym ousgrantsshould betreated asbeingm adefrom oneperson forpurposesof
determ iningthedoneeorganization’spublicsupport
• DA F sponsordonation should treatasunlim ited publicsupportifthesponsoring
organization specifiesthatthedistribution isnotfrom aparticularDA F orstatesthatno
donorordonoradvisoradvised thedistribution
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Section 4960 Proposed Regulations
• Excisetax on excess rem uneration over$1,000,000
• A pplicabletax-exem ptorganization (A TEO)m ustpay 21% excisetax on
com pensation greaterthan $1,000,000 plusany excessparachutepaym ent
paid toa“covered em ployee”duringatax year
• A TEO isany organization thatisexem ptfrom taxation underCodeSec.501(a),isa
farm ers’cooperativeorganization underCodeSec.521(b)(1),hasincom eexcluded from
taxation underCodeSec.115(1),orisapoliticalorganization described in CodeSec.
527(e)(1)
Covered em ployee’sbaseam ountcalculation,generally,includesrem uneration from all
A TEO sand related organizations,and thatacovered em ployee’sparachutepaym ent
calculation includesallpaym ents(m adefrom allA TEO sand related organizations)thatare
contingenton theem ployee’sinvoluntary separation from em ploym ent
A covered em ployeeisany individualw hoisoneoftheA TEO’sfivehighest-com pensated
em ployeesforthetax yearorw asacovered em ployeeoftheA TEO (orany predecessor)for
any precedingtax yearbeginningafterD ecem ber31,2016
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Section 4960 Proposed Regulations
• Excisetax on excess rem uneration over$1,000,000
• W hetheran em ployeeisoneofthefivehighest-com pensated em ployeesof
an A TEO isdeterm ined separately foreach A TEO,thusrelated A TEO scan
havem orethan 5highestcom pensated em ployeesforayear
• O nceacovered em ployeeofan A TEO alw aysacovered em ployeeaslongaspaym ents
received
• N om inim um threshold tobeacovered em ployee
M ustpay m orethan $1,000,000 oran excessparachutepaym entin ayearforthe4960 tax is
paid
• A grantofalegally bindingrighttovested rem uneration isconsidered tobe
rem uneration paid,and any grantofalegally bindingrighttonon-vested rem uneration
by theA TEO (orarelated A TEO)— forexam ple,underadeferred com pensation plan or
arrangem ent— disqualifiestheA TEO from claim ingarelevantexception
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Section 4960 Proposed Regulations
• Excisetax on excess rem uneration over$1,000,000
• Exclusionsand exceptions
• Statutory exclusion forrem uneration form edicaland veterinary services
• Lim ited hoursexception
M ustm eetalloffollow ingrequirem ents
N ocom pensation orlegally bindingnon vested com pensation forservicesperform ed asem ployeeforA TEO orrelated
A TEO
N om orethan 10% oftotaltim espentperform ingservicesforA TEO and allrelated organizationsisspentperform ing
servicesforA TEO and allrelated A TEO s
D isregard rem uneration paid toan individualw hoisneveran em ployeeoftheA TEO
SafeH arbor-individualnottreated asreachingthe10% threshold ifnom orethan 100 ofserviceprovided A TEO and all
related A TEO s
• N onexem ptfundsexception
N orem uneration paid norlegally bindingdeferred com pensation granted by A TEO,any related A TEO and related controlled
organization oftheA TEO toem ployeeofA TEO
A TEO didn’tpay m orethan 10% orm oreofem ployeestotalrem uneration forservicesperform ed asem ployeeofA TEO or
allrelated organizationsand
A TEO had atleastonerelated A TEO and oneofthefollow ingconditionsapply:
• Ten percentrem uneration condition.A related A TEO paid atleast10 percentoftherem uneration paid by theA TEO
and allrelated organizations;or
• Lessrem uneration condition.N orelated A TEO paid atleast10 percentofthetotalrem uneration paid by theA TEO
and allrelated organizationsand theA TEO paid lessrem uneration totheem ployeethan atleastonerelated A TEO.
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TaxpayerFirstA ctof2019
• TaxpayerFirstA ctenacted in July of2019
• N oticeofIm pendingRevocation
• Revocation forfailuretofile3consecutiveyears
• N otification ofrisk ofrevocation aftertw oconsecutiveyearsofnon-filing
• M andatory E Filing
• Fortax yearsbeginningon orafterJuly 2,2019
• Thosefiling990-EZ,havebeen granted aone-yearextension on m andatory e-filing
30. withum.com
O ther
• Group Exem ption
• A sofJanuary 1,2019,IRSstopped m ailinglistsofparentand subsidiary
accountstocentralorganizations(group rulingholders)forverification and
return.Centralorganizationsm uststillcom ply w ith theannualreporting
requirem entsin Section 6ofRevenueProcedure80-27.A snoted in the
RevenueProcedure,therequired inform ation [changes]m ustbesubm itted
atleast90 daysbeforethecloseofthecentralorganization’sannual
accountingperiod.Iftherearenochanges,thecentralorganization m ust
subm itastatem enttothateffect
• N otice2020-36 proposesRevenueProcedureUpdatingGroup Exem ption
LetterProgram w hich w aslastaddressed in Rev.Proc.80-27
31. withum.com
O ther
• ScheduleB
• Donornam esand addressnow required only for501(c)(3)and 527 political
organizations
• FinalRegulationspublished in FederalRegisteron M ay 28,2020 replaceRev.
Proc.2018-38thaton July 30,2019w assetasideby theUnited States
D istrictCourtfortheD istrictofM ontana,asoriginalprocedurehad not
been subjecttonoticeand com m entprocedures
• Effectiveon M ay 28,2020
• O rganizationsm ay choosetoapply thischangetoreturnsfiled afterSeptem ber6,2019
• A llother501(c)organizationscan use“N /A ”in thenam e/addresssection
• Review statelaw sforcharitablefilingsasinclusion ofScheduleB,w ith
nam eand addresscom pleted areon theupsw ing
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PollingQ uestion #4
• A n organization exem ptfrom tax underIRC Section 501(c)(3)can now
fileaScheduleB aspartoftheirForm 990 and notincludedonor
nam esand addressesofdonorson ScheduleB?
A .True
B. False
33. withum.com
O ther
• M ayoClinicv.U.S.,D.M inn.,N o.0:16-cv-03113,appealfiled 10/4/19
• W hat’saschool?
• Regulatory authority ofIRS?
• Collegeand University Endow m entExciseTax
• TheTCJA im posed a1.4 percentexcisetax on thenetinvestm entincom e(N II)of
privateinstitutionsw ith m orethan 500 full-tim eequivalentstudentsand assetsof
atleast$500,000 perstudent.Theproposed rulesdefineterm sintended toprovide
collegeadm inistratorsaroadm ap fordeterm iningw hetherthetax appliestotheir
institution and ifso,how tocalculatetheam ountoftax
• Proposed Regulationsissued July 2019
• https://w w w .insidehighered.com /new s/2020/02/18/w ealthiest-universities-are-
paying-big-endow m ent-tax-bills-how -m uch-are-others-w ho
